In the 1932 case of Consolidated Textile Corp. v. Gregory, Judge, the United States Supreme Court ruled that a federal court could not enjoin state court proceedings in a labor dispute under the circumstances presented by this case. The textile corporation had sought an injunction against a North Carolina judge to prevent him from enforcing penalties for contempt of court after it violated his order prohibiting interference with union activities among its employees. The Supreme Court held that while federal courts do have some power to restrain state court actions, they should use such authority sparingly and only when necessary to protect their jurisdiction or effectuate their judgments - conditions which were not met in this instance.

In the dissenting opinion for Consolidated Textile Corp. v. Gregory, Justice Brandeis argued that the majority's decision to grant a writ of prohibition against Judge Gregory was an overreach of judicial power and violated principles of federalism. He contended that it is not within the Supreme Court's purview to interfere with ongoing state court proceedings unless there is clear evidence that those proceedings are in violation of constitutional rights or federal law, which he did not believe was present in this case. Furthermore, he asserted that granting such a writ could potentially undermine public confidence in state courts by suggesting they cannot be trusted to uphold their own laws without interference from higher authorities. In essence, Justice Brandeis believed strongly in respecting states' autonomy and limiting federal intervention into their affairs.